The underlying dispute in this case involved a commercial transaction between H2O Environmental, Inc. (H2O) and Farm Supply Distributors, Inc. (Farm Supply). Following a bench trial, H2O was awarded $7,354.64 for Farm Supply’s breach of an express oral contract. The magistrate court subsequently awarded attorney’s fees to H2O pursuant to Idaho Code section 12-120(3), but limited its award to the amount in controversy. H2O appealed to the district court, claiming that the magistrate court abused its discretion. The district court affirmed and awarded attorney’s fees to Farm Supply. H2O timely appealed. The Idaho Supreme Court determined the district court erred when it affirmed the magistrate court’s award of attorney fees: nothing in the record explained the relationship between the magistrate court’s evaluation of the Idaho Rule of Civil Procedure 54(e)(3) factors and its decision regarding the amount to award for attorney’s fees. “It is not enough for a trial court to acknowledge the existence of the Rule 54(e)(3) factors; rather, it must appear that there is a reasoned application of those factors in the trial court’s decision regarding the amount of attorney’s fees to be awarded.” The Supreme Court reversed and remanded for further proceedings. View "H20 Environmental v. Farm Supply" on Justia Law

This case stems from the foreclosure and lien priority case arising out of the failed Idaho Club golf course and residential housing development project. The developer, Pend Oreille Bonner Development, LLC (“POBD”), took out several loans on the real property, agreed to promissory notes, and mortgaged the Idaho Club real property with several lenders, including JV, LLC and, as relevant to this appeal, three other lenders: RE Loans (“REL”), LLC, Pensco Trust Co., and Mortgage Fund ’08 LLC (“MF08”) (collectively, the three “lenders”). JV’s interest in the Idaho Club arose out of a mortgage (the “JV Mortgage”) it recorded against five parcels on the Idaho Club property that JV sold to POBD. POBD ultimately defaulted on its obligations on the promissory notes associated with the mortgages. In addition to defaulting on the notes, POBD failed to pay property taxes to Bonner County for several years and failed to pay various mechanics and materialmen, one of which was Genesis Golf Builders, Inc. (“Genesis”). JV appealed the district court's conclusion that Valiant Idaho, LLC (“Valiant”) held a priority position in the mortgages on the development. JV also appealed the district court’s award of costs against it, as well as a judgment by the district court that awarded sanctions against JV and its attorney. The Idaho Supreme Court affirmed in part and vacated in part, finding JV's redemption deed did not subordinate it to Bonner County's right, title, claim and interested based on a tax deed. The Supreme Court also found the district court abused its discretion in the way that it applied the formula announced in Valiant Idaho, LLC v. North Idaho Resorts, LLC (No. 44583, 2018 WL 4927560) to arrive at its costs award. View "Valiant Idaho v. JV, LLC" on Justia Law

This was an action arising out of a failed golf course and residential development project known as the “Idaho Club.” North Idaho Resorts, LLC (“NIR”) appealed an award of discretionary costs and costs as a matter of right awarded against it, contending the district court abused its discretion by awarding discretionary costs, and that the court’s award of some costs as a matter of right was erroneous. After review of the district court record, the Idaho Supreme Court determined the district court abused its discretion by using a formulaic analysis in this case, and by awarding some costs as a matter of right against NIR. The district court judgment was reversed and remanded for further proceedings. View "Valiant Idaho v. No. Idaho Resorts" on Justia Law

Jeffrey Alwin appealed his conviction after a jury found Alwin guilty of felony eluding a peace officer. Alwin moved for a new trial, challenging the district court’s admission of a booking photograph at trial. Alwin argued the booking photograph was evidence of prior criminal conduct in violation of Idaho Rule of Evidence (“I.R.E.”) 404(b). The district court denied his motion. Alwin timely appealed and contended the district court abused its discretion in denying his motion for a new trial because the district court erroneously admitted I.R.E. 404(b) evidence over his objection when it admitted the booking photograph at trial. Alwin also argued the State committed prosecutorial misconduct during closing arguments. The Court of Appeals reversed, and the State filed a timely Petition for Review. The Idaho Supreme Court concluded the trial court did not err in admitting the photograph, did not abuse its discretion in denying a new trial, and found the error committed by the prosecution did not rise to the level of fundamental error. Therefore, the Court affirmed the trial court. View "Idaho v. Alwin" on Justia Law

This case stemmed from a dispute regarding Idaho First Bank’s (“IFB”) efforts to collect on a note secured by a deed of trust. IFB appealed a district court order granting summary judgment in favor of debtors Maj-Le and Harold Bridges (the “Bridges”). The Bridges began leasing land from the Idaho Department of Lands (the “State”) in 2005, with the intent to build a cottage on the land. In 2014, the Bridges entered into a new nine-year term lease agreement with the State. This new lease contained a provision classifying buildings and structures on the leased land as “Personal Property.” This provision was not in the original 2005 lease agreement. In May 2015, the Bridges defaulted on the note. The Bridges then tendered both the cottage and the lease to IFB. On June 19, 2015, IFB filed suit, seeking a judgment on the note without taking action to foreclose on the deed of trust. Significant here, more than three months later, IFB amended its complaint a second time, claiming two separate causes of action seeking a deficiency judgment in the sum of $344,377.24. The first cause of action sought a deficiency under Idaho Code section 28-9-615, with IFB continuing to maintain that the 5000-square-foot cottage was personal property; the second cause of action sought the same relief on the basis of Idaho Code section 45-1512, relative to trust deeds and real property. The Bridges moved for summary judgment against IFB’s deficiency claims, arguing: (1) the cottage was not personal property, making the claim pursuant to section 28-9-61 erroneous; and (2) IFB’s deficiency claims were time barred because they were not filed within three months after foreclosure of the deed of trust, as required by section 45-1512. Finding no reversible error in the district court order, the Idaho Supreme Court affirmed the grant of summary judgment. View "Idaho First Bank v. Bridges" on Justia Law

This appeal related to a purported agreement resolving a lawsuit between Kevin Seward and Musick Auction, LLC (“Musick”). Seward claimed that the parties entered into a binding oral settlement agreement and he moved to enforce the agreement. The district court granted Seward’s motion. Musick contended on appeal the district court erred in several respects when it held that the parties had entered into a binding settlement agreement. Finding no reversible error in the district court's judgment, the Idaho Supreme Court affirmed. View "Seward v. Musick Auction, LLC" on Justia Law

Jane Doe (2018-24) (“Mother”) appealed a magistrate court’s decision to terminate her parental rights over her daughter (“K.O.”) on grounds of neglect after finding it was in K.O.’s best interest. On appeal Mother contested the magistrate court’s findings that: (1) early permanency for K.O. was appropriate and a continuance of trial was not warranted; and (2) that mother neglected K.O. and it was in the best interest of K.O. to terminate Mother’s rights. After review, the Idaho Supreme Court found the magistrate court did not abuse its discretion in failing to continue the trial. Additionally, substantial and competent evidence, to a clear and convincing standard, supported the magistrate court’s decision that Mother neglected K.O. and it was in K.O.’s best interest to terminate Mother’s parental rights. View "IDHW v. Jane Doe (2018-24)" on Justia Law

John Bernal appealed his convictions for assault with a deadly weapon, reckless driving, and leaving the scene of an accident. Carmen Becerra and Bernal dated for approximately eight years. By March 2016, their relationship was strained. One afternoon, Carmen was visiting her cousin; Bernal showed up and asked her if they could talk. Carmen agreed to meet Bernal at his aunt’s house. Carmen and Bernal eft the house in separate cars. Stopped by construction, Bernal got out of his vehicle and walked toward Carmen, who was stopped behind him. Carmen testified Bernal looked angry, so she turned onto a side street to avoid a confrontation. Carmen testified she was driving fast so she could get away from Bernal, but he got back into his vehicle and followed her. While Bernal was following Carmen, she was on the phone with her brother, Gustavo Becerra. Gustavo testified that he could hear screaming, speeding, braking, commotion, and then Carmen abruptly hung up. Carmen hit her brakes, causing Bernal to lose control, spin out, and crash into a parked vehicle. Carmen drove to her home where she lived with her mother, Gustavo, and Gustavo’s family. Bernal arrived on foot. As Bernal was approaching the house, Gustavo told Bernal to leave. When Bernal made it halfway through the yard, Gustavo, who was still on the porch, picked up his baseball bat. An altercation ensured; Bernal left threatening to return. During closing arguments, Bernal argued he did not have a knife, that Gustavo was not a credible witness, and that Gustavo was the aggressor. He also argued that he was not identified as the driver of the car that collided with the parked car. Additionally, Bernal argued Carmen credibly testified, contrary to her previous statement to the police, that she did not see Bernal with a knife. The jury found Bernal guilty on all counts, including the sentencing enhancement, and the district court entered judgment. The Idaho Supreme Court determined Bernal failed to show fundamental error arose from an impermissible variance or from prosecutorial misconduct. Therefore, the Court affirmed Bernal's conviction. View "Idaho v. Bernal" on Justia Law

Carla Sparks appealed an Idaho Industrial Commission decision, which affirmed an Idaho Department of Labor (“IDOL”) finding that she was not entitled to unemployment benefits after being discharged by her employer, Laura Drake Insurance and Financial Services, Inc. (“Drake Insurance”). The appeals examiner held a telephonic hearing to determine Sparks’ unemployment benefit eligibility, but Sparks failed to appear. As a result, Laura Drake’s sworn testimony about the details of Sparks’ termination was undisputed. The appeals examiner found that Sparks was terminated for cause and thus was not entitled to unemployment benefits. The Commission affirmed, and Sparks appealed to the Idaho Supreme Court. The Supreme Court determined Sparks was properly found ineligible for unemployment benefits and the hearing officer/Commission’s denial of her request to provide additional evidence after the initial hearing was not an abuse of discretion. View "Sparks v. Idaho Dept of Labor" on Justia Law

Phil Hart appealed a district court’s grant of summary judgment dismissing his action contesting the results of a primary election for a State legislative seat. The district court ruled Hart had failed to demonstrate that any irregularities in the election were “sufficient to change the result” - an essential component of an election challenge under the Elections Contests Act, Idaho Code sections 34-2101–34-3128. Hart appealed, but finding no reversible error, the Idaho Supreme Court affirmed. View "Hart v. Idaho Secretary of State" on Justia Law